Achieving Compliance with the Stormwater Rule & Other Environmental Rules for Auto Salvage Yard

1. Achieving Compliance with the Stormwater Rule& Other Environmental Rules for Auto Salvage Yard Prepared by the Small Business Environmental Assistance Program

2. Partnership for Clean Waters

3. Small Business Environmental Assistance Program Partnerships for Clean Water in Tennessee

4. Small Business Environmental Assistance Program What is the SBEAP? A technical, administrative, and regulatory support program on environmental issues for small businesses

5. How We Can Help You? • Workshops like the one today • Free confidential Site Visits • Hands on Help with Permits and compliance assistance • Helpful Materials - Brochures, Videos and Handouts • Access to Free Local Assistance

6. Workshop Objectives • Educate the auto salvage industry on the impacts of Storm water run-off • Explain the Storm water Rule and Policy and their regulatory impacts • Explain other environmental laws impact the auto salvage industries • Review and encourage Best Management Practices for handling day to day operations to reduce exposure risk and pollution • Provide resource and assistance information

7. View Video

8. Workshop Topics • Storm Water Runoff • Clean Water Act • Storm Water Permit • Notice of Intent (NOI) • Storm Water Pollution Prevention Plan • Environmental Rules • Best Management Practices

9. Storm water runoff is simply rain water or ice and snow melt that runs off the land into streams, rivers, and lakes. When storm water runs through polluted sites it picks up pollutants and transport them into water ways. Storm Water Runoff ...

10. Storm Water Pollutants • Oil & Grease • Transmission fluids • Hydraulic fluids • Antifreeze • Lawn care chemicals • Toxic chemicals • Sediment • Bacteria

11. Pollute our drinking water supply Restrict swimming area Kills fish Fish consumption advisories have been issued in Tennessee Storm water Pollution Harms Our Environment ...

12. Protecting Storm Water Benefits your Business • Professionalism and pride in your business • It’s the Law • Environmental Protection

13. Regulatory Hierarchy … • Congress (Clean Water Act) • Environmental Protection Agency (EPA) • Code of Federal Regulations (CFR) • States (Tennessee Multi-Sector Permit) • Local (Permit, Policy, and Guidance)

14. Clean Water Act … • 1899 Rivers and Harbors Act • 1948 Federal Water Pollution Control Act (FWPCA) • 1965 Water Quality Act • 1970 Refuse act Permit Program • 1972 FWPCA Amendment • 1977 Clean Water Act • 1987 Water Quality Act

15. Water Quality Act of 1987 … • The law allowed the EPA to govern storm water discharges from 11 categories of industrial activities and construction sites • Discharge of Storm Water was associated with Industrial Activity • 11 categories of industrial activities include manufacturing, processing, materials storage, recycling, mining oil and gas, hazardous waste facilities, landfills, steam electric power plants and more…

16. Storm Water Permit • Individual permit • Requires more Monitoring • More Expensive to implement • Tennessee Multi-Sector Permit (TMSP)

17. How to apply for a Storm Water Permit? • Prepare Storm Water Pollution Prevention Plan (SWPPP) • File Notice of Intent (NOI) for the TMSP with regulatory Agency

18. Storm Water Pollution Prevention Plan

19. Prepare a Stormwater Pollution Prevention Plan … • Identify items to be included in SWPPP • SWPPP Coordinator • Create a SWPPP Team • Identify Responsibility Each Member • Implement the SWPPP Plan • Implement and Oversee Employee Training • Conduct inspection and Monitoring • Oversee maintenance practices of the SWPPP • Prepare and submit report

20. Prepare a Stormwater Pollution Prevention Plan … • Facility Description • Site Map • Facility Location • Site Activities • Site Description • Storm Water Drainage System

21. Prepare a Stormwater Pollution Prevention Plan … • Inventory of Potential Pollutant Sources • Significant Material Inventory • Historic Spill and Leak Record • Potential Areas for Storm Water Contamination • Available Storm Water Sampling Data

22. Prepare a Stormwater Pollution Prevention Plan … • Storm Water Management Control • Compliance with Other Programs • Resource Conservation Recovery Act (RCRA) • Storm Water Management Practices • Best Management Practice (BMPs) • Storm Water Treatment

23. Facility Monitoring Requirements … • Three Types of Monitoring • Visual Examination • Compliance Monitoring • Analytical (Chemical) Monitoring

24. Visual Monitoring Requirements … • Quarterly examination of discharge • Color • Odor • Solids • Foam • No analytical tests

25. Compliance Monitoring … • Annual Compliance Inspection • Required Annually • Determine Best Management Practices Implemented • Operational Change

26. Analytical Monitoring • Required Annually • Grab Sample(s) • Required to Submit Results • March 31st of the Following Year

27. Compliance and Reporting Requirements • Employee Training • Implementation of SWPPP Schedule • Record Retention (three years) • Principal Executive Office Signature • Provision for Amendment of the Plan • Corporate Certification

28. Notice of Intent (NOI) Storm Water Application Review

31. When will the Storm Water Permit Expire? • Storm water permit expires every 5 years • Storm water permit for auto salvage yard expires December 31, 2006

32. Annual fees • No fee for facilities less than one acre • $250 for facilities equal to or greater than one acre and less than five acres • $300 for facilities equal to or greater than five acres and less than 10 acres • $450 for facilities equal to or greater than 10 acres and less than 25 acres

33. Other Environmental Laws for Auto Salvage Yard • Resource Conservation Recovery Act (RCRA) • Comprehensive Environmental Response Compensation Liability Act (CERCLA)

34. More about RCRA ... The Resource Conservation and Recovery Act (RCRA) regulates the generation, storage, disposal, and treatment of wastes.

35. RCRA Goals ... • Protect us from the hazards of improper waste management • Conserve energy and natural resources by recycling and recovery • Reduce or eliminate waste • Clean up waste, which may have spilled, leaked, or been improperly disposed of

36. Types of waste • Solid Waste • Non-hazardous waste • Hazardous waste • Special waste

37. Definition of Hazardous Waste • Hazardous waste exists in many forms such as solid, liquid and gas. • How do we know we have hazardous waste? Hazardous waste are either listed or they exhibit any of four characteristics: ignitable, corrosive, toxic, or reactive (flammable)

38. Tell me more … • There are three main types of generators of hazardous waste: - Conditionally Exempt Small Quantity Generator(CESQG), less than 220Ib (100kg) a month - Small Quantity Generator (SQG), more than 220 Ib (100 kg) less than 2200 Ib (1000kg) a month • Large Quantity Generator (LQG), more than 2200 Ib (1000 kg) a month

39. Requirements for CESQG • Identify your hazardous waste • No more than 2200 pounds (1000 kg) of hazardous waste accumulated at any one time • Comply with storage quantity limits • Ensure proper treatment and disposal of your waste

40. Requirements for SQG • Get an Environmental Protection (EPA) Identification Number • Obtain a copy of EPA form 8700-12 • Fill in the form completely • Send the form to State Division of Solid Waste Management

41. Requirements for SQG • No more than 13200 pound ( 6000 kg) of hazardous waste accumulated at an one time • Comply with storage quantity limits • Ensure proper treatment and disposal of your waste

42. Selecting a transporter of Hazardous Waste Determine your needs: - Quantity - Types - Costs - References - Permits - Insurance - Compliance history

43. Best Management Practices

44. Best Management Practices for Auto Salvage Yards … • Drain all fluids from vehicles upon arrival at the site. Segregate the fluids and properly store and dispose of them. • Keep waste stream separate (i.e waste oil and solvents). Non-hazardous substances that are contaminated with hazardous substances are considered a hazardous waste.

45. Best Management Practices for Auto Salvage Yards … • Recycle antifreeze, gasoline, used oils, and solvents • Dispose of greasy rags, oil filters, batteries, and spent coolants properly • Label and track the recycling of waste materials • Promptly transfer used fluids to the proper container

46. Best Management Practices for Auto Salvage Yards … • Plug floor drains that are connected to the storm sewer • Filter storm water discharges with devises such as oil-water separators • Train employees on proper waste control and disposal procedures • Store batteries on impervious surface. Curb, dike or berm this area

47. Best Management Practices for Auto Salvage Yards … • Confine storage of parts, equipment and vehicles to designated areas • Cover all the parts storage areas with permanent roof or temporary cover (canvas tarps)

48. Best Management Practices for Hazardous Waste • Use a container compatible with type of waste generated • Keep accumulation containers closed except when adding or removing waste • Label containers with words “Hazardous waste” • Mark accumulation start date on container • Do not mix hazardous waste with non-hazardous waste • Meet record-keeping and reporting requirements

49. Benefits of Best Management Practices • Cleaner, Safer Shops • Healthier work environment, with potentially fewer employee sick days • Reduced potential for exposures • Waste reduction

50. Benefits of Best Management Practices • Lower costs • Easier to meet regulatory requirements • Reduced pollutant emissions • Better worker protection and satisfaction